The
economy in the U.S. has been rough on many companies over the last few years.
Many of the major U.S. tech companies have huge amounts of money sitting in
overseas accounts that they argue could be used to fund hiring and other
programs at home.

The catch is that the tax rate on bringing that foreign money home is a
blistering 35% according to CNN Money. These companies are backing
a major lobbying campaign to get lawmakers in Washington to give them a tax
holiday that would allow the foreign money reserves to be brought home at a
massive savings on tax day. The major companies are lobbying for a tax rate on
the money in the area of 5%.

The lobbying push is still in the planning
stages, but so far major tech firms Oracle, Cisco, and Apple are backing the efforts.
Other major companies include Duke Energy and Pfizer. Between these firms, they
have an estimated $1 trillion squirreled away in foreign accounts.

The lobby effort hopes to win that steeply discounted 5% tax holiday for
backers for a full year. The goal is to get the tax holiday included in the
reform package. If the overall reform package fails in Congress, CNN
Money reports that the firms will attempt to push their tax holiday
agenda separately.

The fight for the tax holiday is going to be hard on the companies and the
lobbyists. Congress approved a similar tax holiday in 2004 as part of a package
to promote new jobs in the U.S. and many of the companies that took advantage
of the holiday to bring foreign money home instead used the money as dividends
for shareholders. A study that looked at the holiday conducted by the National
Bureau of Economic Research found that for each dollar of cash brought home in
that holiday the companies bumped shareholder payouts in the area of 60 to 92
cents.

Kristin Forbes, co-author of the study, said, "A tax holiday would bring a
substantial amount of cash back to the United States and paying that out to
shareholders is good for the economy. But if you're a politician claiming this
will create a lot of jobs or new investment, it isn't supported by the
data."

This time around the companies aren’t hiding the fact that some of the loot
brought home would be handed directly to shareholders. However, the companies
are also claim that the tax holiday would allow them to boost markets and
increase consumer confidence and the tax revenue from bringing the funds home
could allow as much as $50 billion in credits to encourage new hiring.

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I think the point these companies are trying to make is that the tax rate for brining this money home makes it not worth doing. If they leave it overseas, which apparently is the right decision, then no taxes will be collected on it, at least not by our government. They could lower that tax rate all the way down to 0.00001% and the taxes collected would still be inifinitely higher than what is being collected on it now.

Also, what's up with your title? This isn't about how much money Larry or Steve have, it's about how much the tech companies have tied up overseas. Besides, who are you to determine how much is "enough" money?

One last thing. I though Steve Jobs was a committed leftist. I'm surprised that he would argue for lowering any taxes for any person or corporation.

I worked in Canada for a few years. One of the things I had to grapple with was international taxes. Apparently the U.S. is unusual in that if you're a U.S. citizen, the U.S. taxes all your income. Most countries tax based on residence. If you're Canadian and live in Canada more than half the year, you pay Canadian taxes. If you're Canadian living in the U.S., you pay no Canadian taxes.

But I'm a U.S. citizen, so the U.S. taxes everything I make regardless of where I make it. This meant that if I lived in Canada, I would be double-taxed. Canada would tax me because I lived in Canada. The U.S. would tax me because I am a U.S. citizen. There's a tax treaty between the two countries covering earned income - basically the income tax I paid to Canada gave me a tax credit which I could apply to my U.S. income tax (since Canadian income taxes were greater, I paid no U.S. income taxes). But unearned income like interest on my savings account, mutual funds, etc. would have been double-taxed. Canada also doesn't recognize the Roth IRA as a retirement account, and I would've had to pay Canadian taxes on the interest I earned on it (even though it was a U.S. account and funded with U.S. money I earned before moving to Canada).

So I ended up living just across the border in Washington and commuting to work in Vancouver every day. Yeah it was a hassle and ecologically unfriendly (fortunately Vancouver has a good public transportation system), but it was the only way to avoid being double-taxed on my non-job income.

Anyway, my point with all this is that international tax structures are in no way consistent nor make any sense. They just are the way they are. You think the sales tax loophole between states is bad? International taxes are even worse. Trying to draw a parallel between how taxes between two countries mesh with how taxes are handled domestically is fruitless - there are just too many exceptions, loopholes, and treaties to draw a reasonable analogy.

And in fact the one way to do taxes which makes the most sense to me (tax based on where the money is earned) is not the position held by most countries (including the U.S.). I would have gladly paid a source-based tax. But the way the tax structures were set up between the two countries meant my choices were to avoid Canadian taxes (except for my Canada-based job) and pay only U.S. taxes, or to be double-taxed. I'm not stupid; I chose not to be double-taxed. It means Canada is not getting tax on interest income I'm earning in my Canadian bank account. That's unfair for Canada, but then double-taxing me on everything is even more unfair for me. There was no way to solve the situation without it being unfair for someone.

The money these companies hold overseas for the most part isn't money that they made in the U.S. It's money they made in other countries. Yet the U.S. government feels that if it should be brought into the U.S., they are suddenly entitled to 35% of it. That's the part that seems to make no sense. Unfortunately it's difficult or impossible to distinguish between a company moving money out of the U.S. to avoid paying any taxes on it, and a company moving money out of the U.S. to fund legitimate operations overseas. So the U.S. takes a "assume the worst case" approach and just taxes everything coming in as if everyone were trying to dodge taxes.

There is no right or wrong answer here. It simply is the way it is. Leave the tax rate at 35% and you collect on tax dodging companies who try to bring their money back in. But you also prevent legit companies from using money they make overseas to expand business in the U.S. Drop the tax rate to 5% and you allow legit companies to use money they make overseas to expand business in the U.S., but you also allow tax dodgers to bring their money back in cheaply.

You said that the Federal Income tax was offset within the Canadian tax, so that isn't doubled.You don't live a specific state, so you aren't paying income tax to a state.You would pay Earnings taxes, but remember - you will still receive those benefits if you remain an expatriat.

Sorry if I didn't explain clearly. My wages wouldn't have been double taxed because the U.S. and Canada have a tax treaty to cover this situation for wages and certain retirement accounts.

My savings, mutual funds, and Roth IRA would have been double taxed had I lived in Canada. e.g. Say my savings account ears $100 in interest, the U.S. takes (say) 25% of that, and Canada takes (say) 30% of that. So I'd be paying $550 in taxes on it, instead of just $25 if I'd lived in the U.S., or $30 if I were a Canadian citizen living in Canada. In the case of the Roth IRA, U.S. tax rate on appreciation of those funds is zero, but Canada didn't recognize it as a retirement account so would tax that appreciation. So yes it is double taxation.

quote: There's a tax treaty between the two countries covering earned income - basically the income tax I paid to Canada gave me a tax credit which I could apply to my U.S. income tax (since Canadian income taxes were greater, I paid no U.S. income taxes).

AFAIK getting a US tax credit equal to your foreign income tax bill is part of standard IRS rules and applies to all foreign income without the need for any treaty.